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DR. SHAKUNTALA MISRA NATIONAL REHABILITATION UNIVERSITY,LUCKNOW.

LAW OF CRIME - 1

PROJECT TOPIC – TYPES OF


PUNISHMENT.

MADE BY – UDAI BAJPAI, 3RD SEMESTER B.COM LLB(Hons.) 2018 - 2019


INTRODUCTION.

Every general public has its own specific manner of social


control for which it
outlines certain laws and furthermore specifies the approvals
with them. These
authorizations are only the disciplines. 'The primary thing to
say in connection
to the meaning of discipline is the insufficiency of
definitional hindrances
meant to demonstrate that one or other of the proposed
legitimizations of
disciplines either sensibly incorporate or consistently
prohibited by definition.
Criminal assents like detainment and capital punishments are
assigned and
apportioned by state specialists. Other formal discipline
include common claims
and authoritative pronouncements to reestablish relations
among the gatherings,
make up for individual wounds, as well as counteract assist
wrongful direct
through confinements of continuous practices. Distinctive
kinds of disciplines
are utilized for various purposes. Criminal sanctions serve to
fortify appreciated
qualities and convictions, cripple and stop the individuals
who might consider
criminal unfortunate behavior, and regularly capacity to keep
up control
relations in a general public and to take out dangers to the
predominant social
request. The control and support of social request is likewise
a vital capacity of
common and managerial approvals. Both formal and casual
disciplines may
additionally serve to sensationalize the fiendishness of
specific lead in a general
public, upgrade mutual solidarity against outside dangers, and
give the way to
social designing endeavors coordinated at enhancing the
personal satisfaction.

Indeed, even a careless take a gander at disciplines, in any


case, uncovers that
they change broadly after some time and place. Formal endorses
by the state or
other "authority" bodies were to a great extent obscure in
prior agrarian social
orders, though social request in current mechanical social
orders is conceivable
as a rule just by a detailed arrangement of formal
authorizations. Variety
additionally happens in the utilization of specific authorizes
inside nations after
some time. A relative verifiable approach offers a significant
method to all the
more completely comprehend this variety in discipline after
some time and
place.An examination of disciplines from a near authentic
viewpoint turns out to
be much more vital inside the present setting of worldwide
economies, world
frameworks, and multinational infiltration. Inside this
inexorably littler and
interconnected world framework, a relative chronicled approach
challenges our
ethnocentric convictions of "good" and "awful" practices in
light of our specific
social and national encounters. The potential revelation of
discipline reactions
and rules that rise above limits of time and space gives a
premise to enhancing
our comprehension of criminal assents and disciplines in
Western and non-
Western social orders alike. The aim of this study is to study
about the
Punishment under IPC, and to analyse the section 302 of IPC.
PUNISHMENT UNDER IPC.

Punishment is a procedure by which the state causes some


torment to the people
or property of individual who is discovered blameworthy of
Crime. At the end
of the day discipline is endorse forced on a blamed for the
encroachment for the
built up rules. The Object of Punishment is to shield society
from insidious and bothersome components by discouraging
potential guilty parties, by keeping the
genuine wrongdoers from submitting further offenses and by
transforming and
transforming them into honest nationals.

The stage of punishment is the final process of the criminal


jurisprudence system. As is well known, one of the fundamental
tenets of criminal law is that„person is considered innocent
until proven guilty‟. Once the court comes to a
conclusion, based on evaluation of the evidence admitted
before the court, that
the accusation are proved against the accused, then the court
necessarily decide
the quantum of punishment to be awarded to the accused.

The object of the punishment in the scheme of modern social


defence is
correction of wrong doer and not wrecking gratuitous punitive
vengeance in the
criminal. The punishments to which offenders are liable are
enlisted under
Section 53 of the Indian Penal Code. Section 53 to 75 of the
Indian Penal Code
1860 deals with the scheme of Punishment. Section 53 of the
Indian Penal Code
prescribes five kinds of punishments.

Section 53 of the Indian Penal Code prescribes five kinds of


punishments are as
Follows :-
a) Death
b) Imprisonment for life
c) Imprisonment, which is of two descriptions, namely –
(1) Rigorous, that is with hard labour.
(2) Simple

d) Forfeiture of property
e) Fine.

Death.
Capital punishment is the harshest of discipline endorsed in
the Indian Penal
Code, which includes the legal murdering or ending the life of
the blamed as a
frame for discipline. The question of whether the state has
the right to take the
life of a person, however, gruesome the offence he may have
committed, has
always been or contested issue between moralists who feel that
the death
sentence is required as a deterrent measure and the
progressies who argue that
judicial taking of life is nothing else but court mandated
murder. The following
are the offences for which a sentence of death may be passed.
Waging or attempting to wage war or abetting the waging of
war against
Government of India (S. 121).
Abetment of mutiny actually committed (S.132).
Giving or fabricating false evidence upon which innocent
person suffers
death (S.194).
Murder (S.302).
Punishment for murder by lifer (S.303).
Abetment of suicide of a child, insane or intoxicated person
(S.305).
Abetment to murder by a person under sentence of
imprisonment for
life; if hurt is caused (S.307).
Dacoity with murder (S.396).

The law vests in the judge a wide discretion in the matter of


passing a sentence
and as such the award of death penalty, except in the solitary
cases provided the
section 303, is left to the discretion of the court. Section
303 I.P.C. which had
left no option to the judge as it made capital sentence
compulsory in the case of
a convict who committed murder while undergoing a sentence of
imprisonment
for life; was however struck down as unconstitutional by the
Supreme Court.

Imprisonment–for Life with Hard Labour, Simple Imprisonment.

Before 1955, the words “transportation for life” was used. The
Code of
Criminal Procedure Amendment Act, 1955 (Act No. 26 of 1955)
substituted the
words “Imprisonment for life” in place of “transportation for
life”. The
punishment of the Imprisonment for Life means imprisonment for
the whole of
the remaining period of the convicted person‟s natural life.

Imprisonment.

Imprisonment is its pure and simple form is a kind of punitive


reaction. Its
object being primarily to deprive the offender of his liberty
which is the most
serious damage which can be caused to a human being, next to
deprivation of
life by death sentence.

The most serious problem associated with imprisonment is what


has been
termed as „prisonization‟
BIBLIOGRAPHY.
[1] Terrance D.Miethe, Punishment, Published by Cambridge
university press, 2005.

[2] Caesar Bonesana, Marquis Beccaruia, Crimes and Punishment,


translated by Edward D. Ingraham, published by Philip H. Nicklin,
No. 175, chesnut st, 1819
.
[3] Peter H.Rossi ,Richard A. Berk, Just Punishment, published by
aldine de gruyter, new York, 1997.

[4] JB.Winsor, The Punishment, published by boulder digital


publishing LLC, 2016.

[5] Thom Brook, Punishment, published by routledge, London and


new York, 2012.
. The prisoner introduced to a new environment which
has its own culture and values, is affected by the direct
impact on the earlier
culture which the prisoner was exposed to before entering the
jail. All that
results in some sort of social debasement of the convict in
his own eyes :
Equally damaging effect is inflicted on family relationship.
Imprisonment for
life ordinarily connotes imprisonment for the whole of the
remaining period of
the convicted persons natural life. The life convict is not
entitled to automatic
release on completion of 14 years imprisonment unless the
government passes
an order remitting the balance of his sentence connotes
sentence to life
imprisonment are detained in jails.

The sentence of imprisonment for life is provided for about 50


offences under
the code.
Kinds of Imprisonment.
Simple imprisonment.
Rigorous imprisonment.

In the case of the former the convicted person is not put to


any kind of work or
labour. There are various offences mentioned in the code which
are punishable
with simple imprisonment only. They are as follows:

Public servant unlawfully engaging in trade or unlawfully


buying or
bidding for property (Section 168 and 169).
Absconding to avoid service of summons or other proceedings
or not
attending to obedience to an order from a public servant
(Sections 172-
174).
Intentional omission to produce a document to a public
servant by a
person legally bound to produce such document or intentional
omission
to give notice or information to a public servant by person
legally bound
to give or intentional omission to assist a public servant
when bound by
law to give assistance (Sections 175, 176 and 187).
Refusing oath when duly required to take oath by a public
servant
(Section 178, 179, 180).
Disobedience to an order duly promulgated by a public
servant if such
disobedience causes obstruction, annoyance or injury (Section
185).
Intentional insult or interruption to a public servant
sitting in any stage
of a judicial proceedings (Section 341).
Uttering any word or making any sound or gesture with an
intention to
insult the modesty of a woman (Section 509).
Misconduct in a public place by a drunken persons (Section
510).

In case of rigorous imprisonment, the convicted person is put


to hard labour but
not harsh labour. A vindictive officer victimising a prisoner
by forcing on him
particularly harsh and degrading jobs violates laws mandate.

The determination of the right measure of punishment is often


a point of great
difficulty and no hard and fast rule can be laid down. It
being a matter of
discretion which is to be guided by a variety of
considerations but the court has
always to bear in mind the necessity of proportion between an
offence and the
penalty. In imposing a punishment it is necessary to have as
much regard to this
pecuniary circumstances of the accused person as to the
character and
magnitude of the offence.
Forfeiture of Property.

Forfeiture of the whole of the property of the criminal is not


possible according
to the present Law. The opinions received by the Law
Commission of India in
its 42nd report, were largely against the introduction of
confiscation of property.
The Commission too was of the view that the harsh punishment
which will fall
not only on the criminal but on his dependent family, is not
to be recommended.
Such a punishment is certainly called in case of smugglers and
black markets
where prima facie the source of income or property acquired by
the offender
may be illegal. As regards hardships to the family, the same
is caused in
varying degrees in all forms punishments. This punishment has
been retained in
the I.P.C. Bill of 1972.

Sections 61 and 62 of the I.P.C. which provided for absolute


forfeiture of all
property of the offender, have been repealed. There are three
cases in which specific property of the offender is liable to
forfeiture, viz.,
where depredation is committed on territories of any power
at peace
with the government of India, such property as is used or
intended to be
used in committing such degradation is liable to forfeiture in
addition to
the sentence of imprisonment and fine (Section 126).
Where property is received knowing the same to have been
taken in the
commission of depredation on the territories of any power at
peace with
the government of India or in waging war against any Asiastic
Power at
peace with Government of India. The property so received is
liable to
forfeiture (Section 125 and 127).
A public servant unlawfully buying or bidding for property
forfeits the
property so purchased. (Section 169).

Fine.

Fine as an additional or alternative form of punishment has


been increasingly
favoured by the law as well as judicial authorities. They are
very frequently
imposed in relation to property crime and the embezzlement,
fraud, theft,
violations of lottery and gambling laws and minor offences
like loitering and
disorderly conduct.

The imposition of fines may be made in four different ways as


provided in the
I.P.C. It is the sole punishment for certain offences and the
limit of maximum
fine has been laid down : in certain offences it is an
alternative punishment but
the amount is limited, in offences where it is imperative to
impose fine in
addition to some other punishment and in offences where it is
obligatory to
impose fine but no particular pecuniary limit is laid down.

As regards the question of quantum of fines, no general


provision exists in
England to regulate it. But both Magna Carta and the Bill of
Rights contain
provisions prohibiting excess and unreasonable fines and
assessment. In I.P.C.
it is observed, that in offences, which are the result of
greedy, the amount of
fines ought to be so excessive as to reduce the offender to
poverty. The
measure of punishment of fine must be carefully regulated and
due regard must
be had to the nature of the offence and the means of the
offender.
The I.P.C. prescribes only the sentence of fine in the
following cases :
The master negligently concealing a deserted on board a
merchant vessel
(Section 137).
The owner or occupier of the land upon which an unlawful
assembly or
riot has taken places if he does not give the earliest notice
at the nearest
police station (Section 154).
Any person for whose benefit a riot is committed and who
does not use
the lawful means to prevent it. (Section 155).
An agent or manager of a person for whose benefit a riot is
committed if
he does not use lawful means to prevent it (Section 156).
Bribery by treating with food, drink etc. (Section 171 E).
A person making a false statement in connection with an
election
(Section 171 G).
Any person incurring illegal payments in connection with an
election
(Section 171-H).
Failure to keep election accounts (Section 171-I).
Dealing in or selling any fictitious stamp (Section 263-A).
Making atmosphere noxious to health (Section 278).
Obstructing a Public way or line of navigation (Section
283).
Committing a public nuisance not otherwise punishable by
this code
(Section 290).
Publication of proposal regarding a lottery not being a
state lottery or
authorized by the Stage Government (Section 295-A).
Section 302 of IPC.

Punishment for murder.-Whoever commits murder shall be


punished with death,
or [imprisonment for life], and shall also be liable to fine.

This section, which prescribes punishment for murder, says


that whoever
commits murder shall be punished either with death or with
imprisonment for
life, and shall also be liable to fine. In other words, the
Indian Penal Code has
prescribed only two kinds of punishment, death sentence and
imprisonment for
life, out of which one has to be imposed on a murder convict
who shall also be
liable to fine if the court so deems necessary.

The section, as is clear, does not enumerate the circumstances


under which
either of these sentences can be imposed. Naturally, the
courts are guided by the
Code of Criminal Procedure and the pronouncements made by the
Supreme
Court in the process. Under section 367(5) of the Code of
Criminal Procedure,
1898, before its amendment in 1955, the normal rule was to
pass a sentence of
death in cases of murder, and if a court was not inclined to
pass such a sentence,
it was required to specifically state the special reasons in
the judgment for doing
so.

In other words, during that time imposition of death sentence


was the rule and
imprisonment for life (transportation for life, before the
same was replaced by
section 117, Schedule of Act XXVI of 1955 to imprisonment for
life) was the
exception. The Code of Criminal Procedure (Amendment) Act,
1955 amended
section 367(5) of the Code of Criminal Procedure, 1898 and
this amendment
came into effect on January 1, 1956. By this amendment that
part of the law
which obliged the court to write reasons for imposing
imprisonment for life was
dropped.
This, in effect, means that the court was empowered to pass
either a sentence of
death or of imprisonment for life at its discretion. The old
Code of Criminal
Procedure was repealed in 1973 when a new Code was enacted.
Section 354(3)
of this Code of Criminal Procedure, 1973 states : „When the
conviction is for an
offence punishable with death or, in the alternative, with
imprisonment for life
or imprisonment for a term of years, the judgment shall state
the reasons for the
sentence awarded, and, in the case of sentence of death, the
special reasons for
such sentence‟.

The ‘Rarest of Rare’ Principle for Imposing Death


Sentence.

As stated already section 354(3) of the Code of Criminal


Procedure, 1973
makes it mandatory for the court to state reasons for the
sentence awarded, and
in case of sentence of death „special reasons‟ for the same.
The Supreme Court
was seized of the question of imposition of death sentence in
Bachan Singh v.
State of punjab1 in which the appellant was held guilty of
murder of three
persons and sentenced to death by the lower court which was
subsequently
confirmed by the High Court.

The question for consideration in appeal was whether the facts


found by the
courts below would be „special reasons‟ for awarding the death
sentence under
section 354(3) of the Code of Criminal Procedure, 1973. The
Supreme Court
observed by a 4 to 1 majority that now, according to the
changed legislative
policy which is patent on the face of section 354(3) the
normal punishment for
murder and six other capital offences under the Indian Penal
Code is
imprisonment for life or imprisonment for a term of years and
death penalty is
an exception. In this context section 235(2) of the Code of
Criminal Procedure,
1973 which is also relevant provides for a bifurcated trial
and specifically gives
the accused a right of pre-sentence hearing at which stage he
can bring on
record material or evidence which may have a bearing on the
choice of
sentence.

The present legislative policy discernible from sections


235(2) and 354(3) is
that in fixing the degree of punishment or making the choice
of sentence for
various offences, including one under section 302, Indian
Penal Code, the court
should not confine its consideration principally or merely to
the circumstances
connected with the particular crime but also give due
consideration to the
circumstances of the criminal.

The Supreme Court should not venture to formulate rigid


standards in an area in
which the legislature so warily treads. Only broad guidelines
consistent with the
policy indicated by the legislature in sections 354(3) and
235(2) can be laid
down. It is quite clear that in making the choice of
punishment or for
ascertaining the existence or absence of „special reasons‟ in
that context the
court must pay due regard both to the crime and the criminal
What is the relative weight to be given to the aggravating and
mitigating factors
depends on the facts and circumstances of the particular case.
More often than
not these two aspects are so intertwined that it is difficult
to give a separate
treatment to each of them. In many cases the extremely cruel
and beastly
manner of the commission of murder is itself a demonstrated
index of depraved
character of the perpetrator.

That is why, it is not desirable to consider the circumstances


of the crime and
the circumstances of the criminal in two separate watertight
compartments. In a
sense, to kill is to be cruel and therefore all murderers are
cruel. But such
cruelty may vary in its degree of culpability. And it is only
when the culpability
assumes the proportion of extreme depravity that „special
reasons‟ can
legitimately be said to exist.

There are numerous other circumstances justifying the passing


of the lighter
sentence; as there are countervailing circumstances of
aggravation. It cannot be
over emphasised that the scope and concept of mitigating
factors in the area of
death penalty must receive a liberal and expansive
construction by the courts in
accord with the sentencing policy. Judges should never be
blood-thirsty.
Hanging of murderers have never been too good for them.

In rarest of rare cases when collective conscience of the


community is so
shocked that it will expect the holders of the judicial power
centre to inflict
death penalty irrespective of their personal opinion as
regards desirability or
otherwise of retaining death penalty, death sentence can be
awarded the
community may entertain such sentiment in the following
circumstances:

When the murder is committed in an extremely brutal,


grotesque,
diabolical, revolting or dastardly manner so as to arouse
intense and
extreme indignation of the community.

When the murder is committed for a motive which evinces


total
depravity and meanness, for example, murder by hired assassin
for
money or reward, or a cold-blooded murder for gains of a
person vis-avis
whom the murderer is in a dominating position or in a position
of
trust, or murder is committed in the course for betrayal of
the
motherland.

When murder of a member of a Scheduled Caste or minority


community
etc. is committed not for personal reasons but in
circumstances which
arouse social wrath, or in cases of bride-burning or dowry
death or when
murder is committed in order to remarry for the sake of
extracting dowry
once again or to marry another woman on account of
infatuation.

When the crime is enormous in proportion, for instance, when


multiple
murders, say of all or almost all the members of a family or a
large
number of persons of a particular caste, community or locality
are
committed.

When the victim of a murder is an innocent child or helpless


woman or
old or infirm person or a person vis-a-vis whom the murderer
is in a
dominating position or a public figure generally loved and
respected by
the community.

Constitutionality of Death Sentence.

It has been held by the Supreme Court in Jagmohan Singh v.


State, that death
sentence is not violative of Articles 14, 19 and 21 of the
Constitution. It cannot
be regarded per se as unreasonable or not in public interest.
The provision does
not suffer from the vice of excessive delegation on the ground
that the
legislature has abdicated its essential function in not
providing by legislative
standards in what cases the judge should pass death sentence.

The provision is not violative of Article 14 on the ground


that unguided and
uncontrolled discretion is given to the judges to impose death
sentence or
imprisonment for life. Death sentence is not unconstitutional
on the ground that
no procedure has been laid by law for determining as to
whether the sentence of
death or a lesser punishment is appropriate in a case.

The same question as to whether death sentence is


constitutional or not again
came up before the Supreme Court in Bachan Singh v. State of
punjab2, which
once again held it constitutional. It was observed that the
provision of death
penalty as an alternative punishment for murder in section 302
is not
unreasonable and it is in the public interest. Therefore,
section 302 does not
have to stand the test of Article 19 (1) of the Constitution.
Retribution and
deterrence are not two divergent ends of capital punishment.
They are
convergent goals which ultimately merge into one.

The provision of death penalty as an alternative punishment


for murder is not
violative of Article 21. The founding fathers of the
Constitution recognised the
right of the State to deprive a person of his life or personal
liberty in accordance
with fair, just and reasonable procedure established by valid
law.

There are several other indications in the Constitution,


including entries 1 and 2
in the Concurrent List specifically referring to the Indian
Penal Code and the
Code of Criminal Procedure, which show that the Constitution
makers were
fully congnizant of the existence of death penalty. By reason
of the same
constitutional postulates, it cannot be said that the framers
of the Constitution
considered death sentence for murder or the traditional mode
prescribed for its
execution as a degrading punishment which would defile the
dignity of the
individual within the contemplation of the Preamble to the
Constitution. On
parity of reasoning, it cannot be said that death penalty for
the offence of
murder violates the basic feature of the Constitution.

Article 6 of the International Covenant on Civil and Political


Rights to which
India acceded in 1979 requires that death penalty shall not be
arbitrarily
inflicted and it shall be imposed only for most serious crimes
in accordance
with a law which shall not be an ex post facto legislation.
These requirements
are similar to the guarantees provided by Articles 20 and 21
of the Constitution
of India.
The Indian Penal Code prescribes death penalty as an
alternative punishment
only for heinous crime which are not more than seven in
number. Section 354
(3) Code of Criminal Procedure, 1973 in keeping with the
abovementioned
International Covenant, has further restricted the area of
death penalty. In
addition to this, section 235 (2), Code of Criminal Procedure,
1973 provides for
hearing of the accused for sentence.

It is implicit in this provision that if a request is made


either by the accused or
by the State or by both, opportunity for producing evidence or
material relating
to various factors relating to a question of sentence should
be given by the
court. Thus, circumstances not only of the crime but of the
criminal as well have
been given due importance.

What is the relative weight to be given to the aggravating and


mitigating factors
depends on the facts and circumstances of the particular case.
For persons
convicted of murder, life imprisonment is the rule and death
sentence an
exception. A real and abiding concern for the dignity of human
life postulates
resistance to taking a life through law‟s instrumentality.

That ought not to be done save in the rarest of rare cases


when the alternative
option is unquestionably foreclosed. In view of the above
section 302 of the
Indian Penal Code and section 354 (3) of the Code of Criminal
Procedure, are
constitutional. Justice Bhagwati who gave a minority opinion
held that section
302, in so far as it provides for imposition of death penalty
as an alternative to
life sentence, is ultra vires and void as being violative of
Articles 14 and 21 of
the Constitution since it does not provide any legislative
guidelines as to when
life should be permitted to be extinguished by imposition of
death sentence.

In Deena alias Deen Dayal v. State3, the Supreme Court


reiterated that
execution of death sentence by hanging as provided by section
354 (5), Code of
Criminal Procedure, 1973 does not violate Article 21 of the
Constitution as the
system of hanging is as painless as possible in the
circumstances and causes no
greater pain than any other known method of execution, and
there is no
barbarity, torture or degradation involved in it.

In Shashi Nayar v. Union of India4, the Supreme Court observed


that the
procedure provided by the law for awarding death sentence is
reasonable. The
death sentence should be awarded in rarest of rare cases and
it does not violate
the mandate of Article 21. The Law Commission had opined in
1967 that the country should not take the risk of abolishing
the death sentence.

Judicial notice can be taken of the fact that the law and
order situation in India
has not improved since 1967 but has deteriorated over the
years and is fast
worsening today. It was also observed that the method of
execution of capital
punishment by hanging is scientific and is one of the least
painful methods and
so no other method seems to be warranted.
Conclusion.

Unsuccessful attempts to change by legislation the provision


of capital
punishment for murder under section 302 of the indian penal
code are reviewed
from the early 1930's to 1971. indian proponents of the
abolition of capital
punishment next directed their efforts primarily toward the
supreme court of
india, which however, rejected in 1972 the abolitionists'
arguments. in effect,
the court reduced the issue to one of whether the legislative
policy of capital
punishment was reasonable in its consideration of the argument
that capital
punishment deprives individuals of essential freedoms. the
possibility of
invalidation of capital punishment through the route of the
lawyer's technique of
statutory interpretation was exemplified in the case of ediga
anamma v. state of
Andhra5, which is discussed at length. four distinct legal
devices used in
justifying life imprisonment rather than capital punishment
for murder are
discussed. it is noted that, aside from the establishment of a
precedent in a few
cases to equally consider the sentences of life imprisonment
and capital
punishment for the crime of murder, no clear subsequent
patterns have emerged.
The offence under section 302 of the Code is cognizable, non-
bailable and noncompoundable,
and is triable by court of session.
INDEX.

TOPIC.
S.NO.

1. INTRODUCTION.

2. PUNISHMENT UNDER IPC.

3. DEATH.

4. IMPRISONMENT–FOR LIFE WITH HARD LBOUR, SIMPLE


IMPRISONMENT.

5. IMPRISONMENT.

6. FORFIETURE OF PROPERTY.

7. FINE.

8. SECTION 302 OF IPC.

9. THE ‘RAREST OF RARE’ PRINCIPLE FOR IMPOSING DEATH


SENTENCE.

10. CONSTITUTIONALITY OF DEATH SENTENCE.

11. CONCLUSION.
ACKNOWLEDGEMENT.

I am extremely thankful to Mr. AMIT PATHAK for Giving me a golden opportunity to


my education.

I am thankful to Mr. PRAVIR KUMAR ,


vice chancellor of law faculty at Dr. Shankuntala Mishra Nationa Rehabilitation
University. Finally I should like to thank my parents and friends one and all who
helped me to complete the project successfully.

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